Thomas Donald Operations Pty Ltd values the privacy of every individual’s personal information (“PI”).
Thomas Donald Operations Pty Ltd is committed to the protection of your PI and meeting the standards set out in the Privacy Act 1988 (Commonwealth) (“the Act”) and the Australian Privacy Principles (“APPs”).
Thomas Donald Operations Pty Ltd gathers information for a variety of reasons, for example to enable it to improve the nature of the services it provides and to facilitate the running of various competitions.
This policy sets out how Thomas Donald Operations Pty Ltd will handle your PI and the rights and obligations that we both have in relation to that information.
1.1 Why Thomas Donald Operations Pty Ltd Collects Personal Information
Generally Thomas Donald Operations Pty Ltd collects all reasonably required for the purposes of providing you with products and services and to administer its relationship with you. Thomas Donald Operations Pty Ltd also collects PI that is reasonably required for marketing purposes and to provide you with information about special events, products and services (both its own and those of other companies) that may be of interest to you. The main purposes for which we collect your PI include:
- to provide you with Thomas Donald Operations Pty Ltd’s products or services;
- to administer Thomas Donald Operations Pty Ltd’s relationship with you;
- to facilitate the running of, and your participation in, trade promotions and other competitions;
- to facilitate the running of and your participation in loyalty programs;
- to monitor activity on Thomas Donald Operations Pty Ltd’s websites, for the purpose of maintaining the security of those websites;
- to compile user databases to enable Thomas Donald Operations Pty Ltd to market goods and services more accurately;
- for internal administrative purposes, such as procedural assessments, risk management, staff training, accounting, billing, product and service reviews; and
- to identify and inform you about other products or services that may be of interest to you.
- The types of PI Thomas Donald Operations collect includes contact details such as name, Date of Birth, Gender, Age, email, Phone and mailing address.
How Thomas Donald Operations Pty Ltd Collects Personal Information
Thomas Donald Operations Pty Ltd primarily collects PI directly from you through written, electronic and/or verbal means of communication when you interact with Thomas Donald Operations Pty Ltd for example when:
- you submit an entry into a competition or trade promotion;
- you participate in loyalty programs;
- you send us an email or post an entry on any of our websites;
- you purchase products from us by credit cards or otherwise.
If Thomas Donald Operations receives PI about you that we did not ask for and it determines that it could have collected this information from you had it asked for it, it will notify you, as soon as practicable, that it has collected your PI. If Thomas Donald Operations could not have collected this PI, it will lawfully de identify or destroy that PI.
Generally, Thomas Donald Operations will use PI only for the purposes for which it was collected.
Thomas Donald Operations may use PI about you for the primary purpose of providing you with its services, and other purposes as listed in Clause 1, for which you would reasonably expect it to use that information, including sending you information about new developments, products, services and special offers by post, telephone or any form of electronic communication. Thomas Donald Operations may use any email address or other personal information you provide to it at any time for this purpose.
If you do not wish to receive marketing or other communications from us, please contact us via the manner set out below so that we can update your preferences. You agree and acknowledge that even if you opt out of receiving marketing material, we will still send you essential information that we are required to send you relating to the services we provide.
If you provide us with your mobile telephone number, email address, IM address or other such personal information, you authorise us to send you promotional messages related to our products and services and the products and services that we promote.
1. third parties engaged by Thomas Donald Operations Pty Ltd to provide functions on its behalf such as processing credit card information, mail outs, debt collection, marketing research and advertising; and
2. third parties authorised by you to receive PI held by Thomas Donald Operations Pty Ltd
We may also disclose PI to unrelated third parties (for example, its professional advisers and government authorities or agencies) where that disclosure is reasonably required to obtain advice, prepare legal proceedings, investigate suspected improper conduct or wrong doing, to assist a lawful authority in the discharge of its duties and/or by law.
Where Thomas Donald Operations Pty Ltd holds promotions in conjunction with other companies, Thomas Donald Operations Pty Ltd will offer you the opportunity to be contacted by its promotions partner. Thomas Donald Operations Pty Ltd will not provide your PI to the promotions partner unless you have opted in to having such PI passed on.
To better protect your privacy, Thomas Donald Operations Pty Ltd imposes strict requirements of security and confidentiality on all third parties as to how they handle your PI. Notwithstanding this, Libsyn cannot be held responsible for any misuse or unauthorised disclosure of your PI by these third parties.
Thomas Donald Operations Pty Ltd takes reasonable steps to ensure that the PI it collects, uses or discloses is accurate, up-to-date, complete, relevant and not misleading. If your PI is incorrect or changes, please contact Thomas Donald Operations Pty Ltd on the numbers below so that it can update your PI and continue providing you with its services.
Your PI is stored in a number of secure computer storage facilities and paper based files, and in other records. Thomas Donald Operations Pty Ltd has taken precautions to ensure that your PI is protected from misuse, loss and unauthorised access, modification or disclosure.
Once Thomas Donald Operations Pty Ltd no longer needs your PI, it takes reasonable steps to de-identify your PI, unless it is required under Australian law or a court or tribunal order it to retain that PI.
If you have any questions whatsoever on Thomas Donald Operations Pty Ltd’s handling of your PI or the kind of PI it holds about you please contact Thomas Donald Operations Pty Ltd on the number below and Thomas Donald Operations Pty Ltd will endeavour to assist you with your request.
Access and Correction
You generally have the right to access your personal information and Thomas Donald Operations Pty Ltd will provide you with a copy of any personal information it holds on request. The APPs set out some circumstances in which Thomas Donald Operations Pty Ltd is not required to provide you such access and if you ask for your PI and any of these circumstances apply, Thomas Donald Operations Pty Ltd will, if reasonable, agree with you on an intermediate approach which would allow sufficient access to your PI to meet your needs.
Thomas Donald Operations Pty Ltd may charge a fee for retrieving PI, in which case Thomas Donald Operations Pty Ltd will inform you of the fee in advance of providing the information.
As required by the APPs, Thomas Donald Operations Pty Ltd does not collect or use Commonwealth Government identifiers when interacting with you.
Where practical, you may deal with Thomas Donald Operations Pty Ltd on an anonymous basis, or with a pseudonym, however, because of the services Thomas Donald Operations Pty Ltd provides, if you do not provide Thomas Donald Operations Pty Ltd with your PI Thomas Donald Operations Pty Ltd may not be able to provide you with the requested product or service (for example, if Thomas Donald Operations Pty Ltd requires your details in connection with a competition Thomas Donald Operations Pty Ltd is running, Thomas Donald Operations Pty Ltd cannot provide you with a prize should you be a prize winner and Thomas Donald Operations Pty Ltd cannot contact you).
2. Overseas Transfers of Information
PI may be transferred to the US Companies, Libsyn and Ooyala which store Thomas Donald Operations Pty Ltd’s databases. Libsyn and Ooyala do not have permission to use, sell, transfer or access PI in any way.
Thomas Donald Operations Pty Ltd will not send your information outside of Australia in any other circumstances, unless Thomas Donald Operations Pty Ltd obtains agreement from the recipient to protect your information in accordance with Australian privacy law including abiding by the terms of this policy or we have your consent.
Sensitive information includes information about your race or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, or details of health, disability or sexual activity or orientation. Thomas Donald Operations Pty Ltd rarely asks for sensitive information, but may do so occasionally as part of competition, promotion or survey, for example.
Thomas Donald Operations Pty Ltd will not require you to provide sensitive information unless:
- you have consented; or
- the collection of the information is specifically authorised or required by law.